Gratify Payments Inc. and our corporate affiliates (“Gratify”, “we”, “us” or “our”) take steps to ensure we meet applicable privacy and data protection principles, guidelines and requirements common to Canada and other jurisdictions to which we are subject. We have developed this privacy policy (the “Policy”) to explain or practices with regards to processing your personal information.  

This policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct, update and access your personal information that you have provided as a user of (a) the websites operated by Gratify from time to time (the “Website”), (b) any front-end software we provide you that interacts or interfaces with the Website (the “Software”), (c) our mobile applications and such other applications as may be made available from time to time (collectively, the “Application”), and (d) the services we provide through the Website, the Software and/or the Application (collectively, “Services”), including, without limitation, email or cloud-based services, excluding any third-party software, websites, application or services that may interacts with the Services (“Third-Party Services”). 

Our Services may contain links to Third-Party Services or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting those Third-Party Services. We have no responsibility or liability for, or control over, those Third-Party Services or their processing of your personal information. We encourage you to read the privacy policies of those Third-Party Services to learn how they process your personal information.  

READ THIS PRIVACY POLICY CAREFULLY.   

This Policy applies to you when you sign up for Gratify Services, access your Gratify account, or use the Gratify Services. By using our Services or otherwise choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in Canada in accordance with this Policy and as may be further identified when your personal information is collected. If you are located or residing outside of Canada, please be aware that our Services are intended for and directed to users in Canada, and the privacy laws and principles in Canada may differ and not offer the same level of protection as those in your location or residing country. Through your continued use of our Services, you are transferring your personal information to Canada, and you expressly consent to that transfer. We will use this consent as the legal basis for such data transfer, unless otherwise stated in this Policy.  

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Services or otherwise provide any personal information to us. 

Collection of Your Personal Information 

For the purposes of this Policy, “personal information” means any identifiable information about an individual, including, but not limited to, an individual’s name, home address, telephone number, email address, except any other information otherwise exempted by the applicable laws of Canada. For example, in Canada personal information does not include any business contact information that is processed solely to communicate with that person about their employment or profession. 

Gratify will only collect, use or disclose your personal information with your knowledge and consent, except when required by law. Gratify only collects personal information that is necessary for us to perform the services you have requested, that is reasonably needed for our business activities, or information that is required by applicable law, court, or tribunal order. We encourage you to not provide us with any personal information beyond what is necessary and as requested by us. 

The types of personal information Gratify may collect when you use our Services are as follows:  

  1. Your contact information, including but not limited to your name, mailing address, telephone number, and email address; 
  2. Personal information, including but not limited to your date of birth, driver’s license number or other forms of identification documents/information; 
  3. Unique identifiers such as username, account number and password; 
  4. Financial information, including but not limited to full bank account and/or credit card details which you will link to your Gratify account when you use our Services; 
  5. Information that can be used to assess credit information, such as employment status, bank account transaction history, and your social insurance number; and 
  6. Information from your interaction with our website from cookies and or other web-based files on your user device. This information includes but is not limited to your computer IP address, type of operating systems, the pages you have accessed, device identifiers, your location, and mobile network information.  

In order to help protect your personal information from fraud, Gratify may collect information about your use and interaction with our Services. 

Your personal information may be collected when: 

  1. You register for an account with us; 
  2. You connect with us through social media; or 
  3. We collect data from third parties of publicly available sources. 

Collection from Third Parties 

Gratify may also collect information about you from third parties like identity verification services, and publicly or commercially available sources for the purpose of complying with relevant legislation including anti-money laundering laws. We do not knowingly collect your personal information for third parties unless you consent or we are otherwise exempted, required or permitted by applicable laws to do so.  

If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected. 

Links to Other Sites 

To the extent that any of our Services contains links to Third-Party Services, the owners of those sites are responsible for the privacy practices or content of those other site. The policies and practices of Third-Party Services are independent of Gratify and may differ from ours. We do not endorse and will not be responsible for the privacy practices on Third-Party Services.   

Age of Majority 

Our Services are intended solely for users who are over the age of majority in their province or territory of residence.  All users must be able to lawfully enter into and form contracts under applicable law. 

We do not knowingly collect personal information on any individual who is underage. No such person, nor any parent or guardian as it relates to such individual, should submit their personal information to us through the Services for any reason under any circumstances.  

Cookies 

Our Website makes use of cookies. Cookies are small text files offered to your computer by servers in order to keep track of your browser as you navigate the Website. Cookies may be stored on your hard drive, or in temporary (cache) memory, in which case they are deleted when you shut down your browser or turn off your computer. We may use cookies to store preferences, record session information such as language preferences, develop aggregate information about Website visitors’ preferences and interests, record past activity at the Website in order to provide better service when you return to our Website, or customize webpage content based on your browser type or other information you provide. Unless a visitor specifically provides their identity to us, cookie information is anonymous, and we will not know who the individual visitors are. Information gathered from cookies is only used on an aggregate basis. You can disable cookies using your Internet browser’s settings, however the Gratify application will not work without cookies enabled.  

Processing Your Personal Information 

Gratify may process your personal information for the following purposes (the “Purposes”):  

  1. To provide you with the Services, assess your application, and determine your eligibility for Services;  
  2. To verify and confirm your identity, including comparing your information with third parties to confirm your identity for the purposes of anti-money laundering, counterterrorism, sanction laws, and internal risk policies; 
  3. To process transactions, collect fees, and send you notices with regards to your transactions; 
  4. To ensure that the Services are optimized for your use and benefit; 
  5. To analyze user experience and improve the Services; 
  6. To operate, maintain and provide to you the Services, including all features and functionality of any of the Services; 
  7. To communicate with you to provide you services, contacts, materials or recommendations for your needs as identified by you through phone, email, the Website or the Application; 
  8. To carry out our obligations arising from any contracts entered into between you and us; 
  9. To investigate and prevent potentially illegal or prohibited activities; 
  10. To comply with all legal, regulatory, accounting, or security requirements, or with internal policies and procedures; or 
  11. To maintain our business records and contact you as permitted by law; 
  12. To share your personal information with our employees, contractors, consultants and other third-party service providers such as application hosting providers, advertising agencies, payment processors or customer service agencies (“Third-Party Processors”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Services for your use and benefit; or 
  13. For any other reasonable purposes for which you consent. 

Please note that we may change or add Third-Party Processors at any time, in our sole discretion, either in Canada or elsewhere. We encourage you to reference this Policy from time to time, to obtain updated information. Given the nature of cloud services, personal information may be stored outside of Canada, anywhere in the world, and may be accessible to foreign courts, law enforcement and national security authorities in jurisdiction(s) where it is transferred or stored. 

We will only process your personal information for the purposes for which we intend to process such information. Otherwise, we will not process your personal information without your consent except where permitted by law. 

To the extent permitted by applicable law, we may process, transfer, and store any data about individuals and customers or partners in an anonymous and aggregated manner. We may combine personal information with other information collected online and offline, including information from third party sources. We may share anonymized data with third parties for the purpose of offering and improving our Services.  

By using our Services, you agree that we are hereby licensed to collect, use, share, and store anonymized aggregated data collected through our Services for benchmarking, analytics, metrics, research, reporting, and other business purposes.  

Disclosure of Your Personal Information 

Gratify may share or disclose your personal information for the purposes as described in this Policy with the following:  

  1. Our employees, contractors, agents, affiliates, business partners, and on an as-needed basis; 
  2. Our retailers/merchants, so that they can provide the goods or services you have requested; 
  3. Financial institutions for the sale or financing of goods or services; 
  4. Credit bureaus and/or collection agencies if installment payments are missed and to collect debt owed to us; 
  5. Our Third-Party Processors; 
  6. Law enforcement, government agencies, regulatory bodies, or other third parties based on court orders, subpoenas, legal and or regulatory requirements, audit purposes, or security requirements; and  
  7. Companies we may plan to merge with or be acquired by, companies who may invest in Gratify, or companies to which we may plan to sell all or substantially all or the assets used in the operation of our business. 

Your personal information that we collect may be processed outside of Canada but only in relation to the Purposes. As a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with other jurisdictions’ applicable laws. 

Security, Storage, and Protecting Your Personal Information 

Gratify will provide your information to our employees and relevant third parties on a need-to-know basis only. We will keep your personal information secure by taking reasonable steps to protect your information from unauthorized access or disclosure, misuse, loss, theft or modification. We will protect your personal information using physical, technological, procedural, and administrative security measures appropriate to the sensitivity of the information. Only authorized employees, contractors, consultants and agents of Gratify who require access to your personal information to perform their job requirements will be able to access your personal information.  

We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity of the information. 

Your personal information may be stored by Gratify and other third parties via electronic or physical files. The electronic files are stored and maintained on our servers which may be located outside of Canada, in which case foreign governments, courts of law, and law enforcement, or regulatory agencies may be able to obtain disclosure of your information.  

There is always some risk in secure data transmission and storage; therefore, despite our security measures and protocols, we cannot guarantee the absolute security of your personal information, nor do we warrant or represent that your personal information will be absolutely protected against unauthorized access or disclosure, misuse, loss, theft or modification. You should always exercise caution when disclosing personal information over the Internet.  

Retention of Your Personal Information 

Gratify will generally retain your personal information only for as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate business purposes. More specifically, we retain personal information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws or to protect our interests. When personal information is no longer necessary or relevant for the identified purposes, or required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retentions and destruction which apply to personal information.  

Requests for Access to and Correction of Personal Information 

Applicable privacy laws allow individuals the right to access and request the correction of errors or omissions to their personal information that is in our custody or under our control. You may request access to and review of your personal information in our possession. However, access may be declined where permitted or required by applicable law. 

You may request that we correct your personal information in our possession. We reserve the right not to change any personal information if we do not agree that it is inaccurate or outdated but will append any alternative text the individual concerned believes to be appropriate.  

If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal. 

Methods of Communication  

Gratify may contact you via SMS texts or email using the telephone number and email address you have provided to us. We may provide you with links for purchases or notify you of payment transactions. All the information you provide to us via text message will be handled in accordance with the terms of this Policy.  

There may be telephone conversations between you and our employees, which may be monitored and recorded for quality control, internal training and/or record keeping, unless you do not consent to being recorded. You always have the right to obtain the recorded copy of your conversation.  

Updates or Changes to this Policy 

Gratify may amend the Policy at any time and from time to time. The latest version of the Policy will be available on the Website and come into effect at the time it is posted on the Website or on the date specified in a notification. Any changes to the Policy will apply to existing information, as well as information collected onwards from the effective date of such changes.  

You should not continue to use our Services if you do not agree with the latest version of the Policy. By continuing to use our Services you agree to and accept the terms of the latest version of the Policy. We will notify you via the SMS text message or email sent to the telephone number or email address associated with your account when any material changes are made to the Policy. 

Residents of Quebec: We will notify you in advance of any changes to the Policy via written notice to the email address associated with your account stating the changes and date the changes will come into effect. You have the right to refuse the changes without penalty by notifying us in writing no later than 30 days after the change comes into effect, in which case you must immediately stop using our Services.  

Concerns, Questions, and Contact Information 

Should you have any questions or concerns regarding this Policy, please contact our Privacy Officer via the following methods:  

  1. Email: support@gratifypay.com  
  2. Phone: 1-888-454-3088 
  3. Mail: Gratify Payments Inc.  2800 – 666 Burrard Street Vancouver, BC, V6C 2Z7, Canada